Modern Slavery Transparency Statement

Statement

The purpose of this statement is to confirm that Hemiko Limited and other relevant group companies ("Hemiko") have taken appropriate steps during the year ending 31 March 2024 to ensure our continued compliance with the Modern Slavery Act 2015 (the "Act"). As a business we are committed to improving our practices to combat slavery and human trafficking in our business and supply chain. We continue our commitment to providing employment opportunities which are non-discriminatory, support living wage legislation, and offer regular hours and working conditions that are safe and hygienic. We are also committed to implementing and enforcing effective systems and controls to ensure that there is no modern slavery or human trafficking taking place anywhere in our own business or in any of our supply chains.

About us

Hemiko is a fast-growing innovative business looking to invest in and deliver over £1bn of heat network projects in the coming years. We fund, design, build, operate and maintain low carbon district energy networks and building energy systems. We work with local authorities, developers, house builders and property owners to decarbonise communities, towns and cities.

Our vision is to be a leader in town and city scale decarbonisation. We operate across the United Kingdom and Denmark and pride ourselves on our reputation for acting fairly and ethically wherever we do business. Our reputation is built on our company values, those of our employees and our collective commitment to acting with integrity throughout the organisation,

Further business information can be found at: https://www.hemiko.com.

Hemiko is heavily reliant on its people and supply chains in the delivery of services. We are also aware of our diverse customer base with a wide range of backgrounds and needs. Each business within the group is responsible for ensuring that they can demonstrate compliance with the Act by working to our policies and procedures.

Our business in relation to slavery and human trafficking

Hemiko prides itself on having a reputation for being a moral and principled employer. We believe this provides a platform to deliver a quality and more consistent service across our contracts and sends a message that we care about the wellbeing of the people working for us.

We support National Living Wage requirements and regularly review our terms of employment to ensure that they comply with all relevant legislation.

All staff employed by Hemiko have identity and Right to Work checks, and where applicable DBS checks prior to employment commencing. These checks are always carried out in line with the relevant legislation and in accordance with UK Government guidance. For certain roles, where additional background checks are required, a more in-depth vetting process can be implemented.

Our HR information system provides us excellent transparency in this area, additionally DBS workflows and reporting to incorporate 2-yearly checks, significantly reducing any compliance risk.

Each year we conduct an engagement survey for our staff which asks them to anonymously comment on their experience in the workplace and beyond. Throughout the survey there are frequent free text fields allowing the opportunity to provide honest feedback or raise concerns. All staff are encouraged to complete the detailed questionnaire and are informed of the purpose. The data collected is used to identify areas of improvement and flag any areas of concerns or issues. We are also in the process of launching targeted surveys for onboarding and exiting staff.

Our supply chain in relation to slavery and human trafficking

We have zero tolerance to slavery and human trafficking. We expect our suppliers to work to the same high standards that we impose on ourselves. We actively promote safe and fair working conditions, including the responsible management of environmental and social issues within our supply chain.

Through our procurement processes we monitor our supply chain to ensure only reputable suppliers and contractors who share those same high standards and comply with our values remain on our preferred supplier list.

As part of our supplier onboarding process, all suppliers are required to complete various due diligence checks and return a signed copy of our Supplier Code of Conduct. We assess our supply chain for potential areas of risk of non-compliance with the Act, considering a number of factors including:

• Suppliers operating outside of the UK;
• Raw materials that are produced, or likely to be produced, outside of the UK / EU;
• Suppliers operating using temporary and/or low skilled labour.

Within our standard tender documents and commercial contracts, there is an obligation for suppliers to fully support and operate in accordance with the Act and take all reasonable steps to ensure that there is no modern slavery in its business or supply chain - Hemiko reserves the right to terminate any supplier relationship where this obligation is not adhered to. We continue to identify and prioritise suppliers that have their own modern slavery policy.

Our Supplier Code of Conduct (the “Code”) includes key modern slavery provisions (i.e. equal pay, working hours compliant with legislation etc.). The Code is integrated into our supplier on-boarding process, meaning all new suppliers are required to review and confirm they will adhere to anti-slavery principles.

We have periodic audits with our key suppliers where safe and fair working conditions, including the responsible management of environmental and social issues within our supply chain, are reviewed.

Processes employed to ensure that slavery is not taking place

Hemiko has a set of policies and procedures which in general cover human rights issues and are aimed at minimising the risk of slavery or human trafficking. Our policies are reviewed on an annual basis, or more regularly as required by any legislative change.

In addition to our Modern Slavery Policy, some of the policies and procedures of particular note are our Supplier's Code of Conduct, Diversity, Equity and Inclusion, Grievance, Harassment and Discrimination, and Whistleblowing, each of which is easily accessible and available to all staff.

Our employee, customers and suppliers are encouraged to report any concerns or suspicions they have that any unlawful conduct, including slavery or human trafficking, is taking place at work. For our staff, we have introduced a dedicated and confidential SpeakUp@hemiko.com email inbox to facilitate this.

We also promote the Modern Slavery Helpline 0800 0121 700 (https://www.modernslaveryhelpline.org), where individuals can report any suspicious activity or seek help and advice in confidence.

In an effort to combat the hidden nature of modern slavery and boost awareness of the signs, we now display posters and infographics created by the UK Home Office (part of the 'Modern slavery is closer than you think' briefing documents) in company offices, and suitable site / project location notice boards. Our regular internal communications provide links to a UK Home Office short film and other relevant information to further educate the business.

Staff training about slavery and human trafficking

Our policies are communicated to staff from the point of induction and regular updates are provided as required through training programmes as the business sees fit.

Our policies and procedures are reviewed on an annual basis, or more frequently where legislation or regulation updates dictate, to ensure that they remain fit for purpose. Of particular relevance are our policies on safeguarding and vulnerability issues, mindful of our diverse customer base and workforce.

Over the next twelve months, we will continue to roll out training to our human resources, procurement, commercial and operational teams to increase their awareness of the Act and our associated due diligence processes. As part of induction training for new starters and refresher training for existing staff, staff are reminded of our core policies, including the Whistleblowing policy and who to contact with any concerns. The HR team conduct Right to Work checks in accordance with the applicable legislation.

Our Commitment

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Hemiko's slavery and human trafficking statement for the financial year ending 31 March 2024 as approved by the Board of Directors 13 August 2024.